Justia Criminal Law Opinion Summaries

A physician was charged with unlawfully distributing oxycodone, a controlled substance, after prescribing it to a patient he knew was addicted to opioids, and who subsequently died of a drug overdose. The government alleged that the prescriptions were not issued for legitimate medical purposes and were outside the usual course of professional practice. The physician pled guilty to all charges in 2019. At his plea hearing, the district court explained that the government would have to prove the prescriptions were unauthorized but, following then-binding Fourth Circuit precedent, did not tell him the government also had to prove he knew his conduct was unauthorized.Nearly three years later, the Supreme Court decided Ruan v. United States, holding that, under 21 U.S.C. § 841, the government must prove that a physician “knowingly or intentionally” acted in an unauthorized manner when prescribing controlled substances. The physician filed a motion under 28 U.S.C. § 2255 to vacate his convictions, arguing his guilty plea was invalid because he had not been informed of the scienter requirement articulated in Ruan. The United States District Court for the Middle District of North Carolina denied the motion, finding the claim procedurally defaulted because it was not raised earlier and that Ruan was not so novel as to excuse the default, since similar arguments were available and made by others at the time of the plea.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that the legal basis for the physician’s Ruan-style mens rea claim was reasonably available at the time of his guilty plea, given existing Supreme Court precedent such as Rehaif v. United States. Therefore, the claim was not sufficiently novel to provide cause to overcome procedural default, and collateral relief was precluded. View "United States v. Dimkpa" on Justia Law

Two individuals were separately stopped and searched by law enforcement officers in Maryland in January 2023, prior to the effective date of a new statute, Criminal Procedure Article (“CP”) § 1-211. The stops and searches were based solely on the odor of cannabis. Contraband was discovered in both cases, and the individuals were charged with various offenses. Each moved to suppress the evidence, arguing that the newly enacted statute, effective July 1, 2023, rendered evidence obtained solely on the basis of cannabis odor inadmissible, even though their searches had occurred before the law took effect.In both cases, the Circuit Court for St. Mary’s County and the Circuit Court for Worcester County denied the motions to suppress, ruling that the statute did not apply retroactively because it was not in effect at the time of the searches. The Appellate Court of Maryland affirmed both decisions, reasoning that the statute created a new substantive right and remedy that only attached to searches occurring on or after its effective date. The Appellate Court relied on its prior decision in Kelly v. State and distinguished these cases from others involving procedural or remedial statutes.Upon review, the Supreme Court of Maryland affirmed the judgments of the Appellate Court. The Court held that CP § 1-211’s exclusionary remedy applies only to evidence discovered or obtained in violation of the statute, and no violation can occur before the statute’s effective date. The Court found the statute unambiguous, rejected arguments for retroactive application based on procedural or remedial theories, and emphasized the General Assembly’s clear intent for prospective application. Therefore, the exclusionary remedy in CP § 1-211(c) does not apply to pre-enactment cannabis-related stops or searches, and the evidence was properly admitted. View "Cutchember v. State" on Justia Law

The case involved a traffic stop in Salem, New Hampshire, where a police officer, upon detecting a strong odor of alcohol in a vehicle, interacted with its passengers. The defendant, seated in the back, became verbally aggressive toward the officer, yelling and cursing. After being ordered out of the vehicle, the defendant stepped toward the officer, pointed at him, and shoved his finger into the officer’s chest. When the officer attempted to arrest him, the defendant pulled away, struggled, and resisted being handcuffed. A portion of this encounter was captured on video by another passenger.Following these events, the defendant was charged in the Rockingham County Superior Court with misdemeanor counts of simple assault and resisting arrest. At trial, the jury was presented with video evidence and heard testimony from the officers involved. The defendant moved to dismiss the charges for insufficient evidence, but the trial court (St. Hilaire, J.) denied these motions. The jury found the defendant guilty on both counts, leading to the present appeal.The Supreme Court of New Hampshire reviewed the case. The defendant argued that appellate review of video evidence should be de novo, asserting that the court was in as good a position as the jury to interpret such evidence. The court rejected this argument, holding that video evidence must be reviewed under the traditional standard: all evidence, including video and live testimony, is viewed in the light most favorable to the State to determine whether any rational jury could find guilt beyond a reasonable doubt. Applying this standard, the court found sufficient evidence to support both convictions. The court also rejected the defendant’s argument that his conduct was de minimis, noting it was not preserved or plain error. The court affirmed the convictions. View "State v. Wells" on Justia Law

A former ship captain was prosecuted after a fire broke out on his vessel, resulting in the deaths of thirty-four passengers and crew members. The ship, used for recreational diving, had multiple fire safety features and regulatory requirements, including the need for a roving night patrol and crew training in fire response. The captain had extensive maritime experience, but his crew was relatively inexperienced and had not been adequately trained in emergency procedures. On the night of the incident, no one was assigned to patrol for fires, and when the fire was discovered, the crew was unprepared to respond effectively. The captain contacted the Coast Guard but did not use the ship’s public address system to warn those below deck or attempt a rescue, ultimately abandoning ship along with other crew members. All individuals below deck died from smoke inhalation and asphyxiation.The United States District Court for the Central District of California presided over the initial criminal case. The first indictment tracked the language of the seaman’s manslaughter statute but was dismissed by the district court for not alleging gross negligence, which the court believed was required based on prior interpretations of a different manslaughter statute. The government reindicted, alleging gross negligence, and the case proceeded to trial. The jury was instructed that conviction could follow if the captain engaged in “misconduct and/or acted with gross negligence.” The jury found the captain guilty.On appeal, the United States Court of Appeals for the Ninth Circuit held that the seaman’s manslaughter statute, 18 U.S.C. § 1115, requires only ordinary negligence, not gross negligence. The court further concluded that, even if the jury instruction’s use of “misconduct” was erroneous, any such error was harmless because the instructions repeatedly referenced the higher gross negligence standard, the prosecution did not argue for a lower standard, and overwhelming evidence supported the conviction. The judgment was affirmed. View "USA V. BOYLAN" on Justia Law

Law enforcement in central Arkansas identified an individual as a source of methamphetamine distribution and arranged a controlled buy using a confidential informant. On March 28, 2022, the informant, equipped with recording devices, purchased over 100 grams of methamphetamine from the individual, who was subsequently arrested. The video and transcript of the transaction captured the exchange, including a discussion about a firearm in the vehicle. Laboratory tests later confirmed the substance’s identity and quantity.The United States District Court for the Eastern District of Arkansas presided over the trial. The defendant objected to the admission of the video, transcript, and related evidence on grounds of inadequate authentication, hearsay, and unfair prejudice due to the firearm discussion. The district court overruled these objections, admitted the evidence, and provided a limiting instruction regarding the transcript. After the jury convicted the defendant of distributing 50 or more grams of methamphetamine, the court sentenced him to 125 months’ imprisonment. The defendant argued at sentencing that he was subject to sentencing entrapment and requested a sentence below the statutory minimum, but the district court denied these requests.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion and the sentencing issues for clear error and plain error. The appellate court held that the video and transcript were properly authenticated, their probative value was not substantially outweighed by unfair prejudice, and the statements in the recording were either admissible as party-opponent admissions or provided contextual background rather than hearsay. The court also found no clear error in the rejection of the sentencing entrapment argument and concluded that the district court adequately explained its sentencing decision. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Walker" on Justia Law

The case concerns Brad Wendt, who owned two firearms stores in Iowa and also served as the Chief of Police for the small city of Adair. As police chief, Wendt had the authority to write official letters (“law letters”) that allowed his stores to acquire machine guns for the Adair Police Department or for demonstration purposes. Over several years, Wendt wrote numerous law letters to acquire ninety machine guns, some of which he resold for significant profit. Evidence showed that these acquisitions and demonstrations were not genuinely for police department use or potential future purchase but were instead for personal gain and to facilitate sales to other firearms dealers. Wendt also arranged for machine guns to be acquired and demonstrated by other dealers without legitimate department interest.After a jury trial in the United States District Court for the Southern District of Iowa, Wendt was convicted on multiple counts, including making false statements, conspiracy to make false statements and defraud the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), and illegal possession of a machine gun. The district court sentenced him to sixty months in prison, imposed a fine, and ordered the forfeiture of firearms. Wendt moved for acquittal or a new trial, but the district court denied these motions.On appeal to the United States Court of Appeals for the Eighth Circuit, Wendt challenged his convictions and sentence. The Eighth Circuit affirmed the convictions and sentence related to false statements and conspiracy, finding that the jury instructions fairly reflected the law and that there was no ambiguity requiring special instruction. However, the court found that the statute criminalizing possession of a machine gun was unconstitutionally vague as applied to Wendt in his role as police chief. The court reversed his conviction for illegal possession of a machine gun, remanded for vacatur of that conviction, but affirmed the remaining convictions and sentence. View "United States v. Wendt" on Justia Law

After unlawfully entering his ex-wife’s home in violation of a court-issued protection order, the defendant was charged with second degree burglary and additional offenses. The protection order, issued under Colorado law, specifically prohibited the defendant from contacting his ex-wife or entering her residence. During the incident, the defendant jumped a fence, damaged property, and entered the home despite his ex-wife’s objections, prompting her to lock herself in the bathroom and call the police. Officers arrived to find the defendant leaving the property, and he was subsequently taken into custody.The Weld County District Court held a preliminary hearing on the burglary charge. The prosecution presented evidence of the defendant’s violation of the protection order. The defendant did not dispute the factual allegations but argued that his conduct did not amount to a “crime against another person or property” under the second degree burglary statute. The District Court, relying on the Supreme Court of Colorado’s decision in People v. Rhorer, concluded that violating a protection order is a predicate crime for second degree burglary because it constitutes a crime against a person or property. The court found probable cause and set the charge for trial.The Supreme Court of Colorado exercised its original jurisdiction to review the District Court’s ruling. The court affirmed the trial court’s interpretation of the law, holding that a criminal violation of a protection order under section 18-6-803.5, C.R.S., categorically qualifies as a “crime against another person or property” for purposes of the second degree burglary statute. Therefore, such a violation may properly serve as the predicate offense for second degree burglary. The Supreme Court discharged the order to show cause and remanded the case for further proceedings. View "People v. Dilka" on Justia Law

In this case, the defendant was observed by New York City police officers driving without a seatbelt. When officers attempted to pull him over, he fled, eventually crashing into a parked car. After the crash, he fled on foot and was seen throwing a green bag over a fence into a construction lot across from a school. Inside the bag, officers later found a loaded firearm with a defaced serial number. The defendant’s photo identification and cell phone were found in the car. He was arrested about a month later during a scheduled meeting with probation.The United States District Court for the Southern District of New York presided over the initial criminal proceedings, where the defendant was indicted, and a jury found him guilty of being a felon in possession of a firearm. Prior to trial, the government missed the court-ordered deadline for expert disclosures under Rule 16 but provided the DNA evidence report to the defense as soon as it was available. The district court found the government negligent but not in bad faith and offered the defendant a continuance, which he declined in favor of a one-day delay before trial. The jury convicted the defendant, and the court imposed a below-Guidelines sentence of 78 months’ imprisonment, followed by three years of supervised release.On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the district court abused its discretion by allowing the DNA evidence despite the late disclosure and whether the sentence was substantively unreasonable. The appellate court held that the district court did not abuse its discretion in admitting the evidence with a continuance, nor was the sentence unreasonable. The court affirmed the conviction and sentence in all respects. View "United States v. Aryeetey" on Justia Law

The case concerns an incident in which Oscar Senior fatally shot Charles Willis on April 13, 2012, in Muscogee County, Georgia. Willis was driving with his cousin, Douglas Body, when they encountered Senior and his girlfriend, Vinyetta Longino. After a brief exchange, Senior fired a handgun at Willis’s car, killing Willis. Several eyewitnesses, including Body, Longino, and others, testified that Senior was the shooter. Evidence at trial included multiple bullet fragments from the car and Willis’s autopsy, as well as testimony about a revolver found near the scene of Senior’s later arrest. Senior’s defense suggested there may have been another shooter and attempted to create doubt based on the number of shots fired.After his 2014 trial in the Superior Court of Muscogee County, a jury convicted Senior of malice murder, aggravated assault, and possession of a firearm during the commission of a felony. The court sentenced him to life imprisonment without parole and additional concurrent and consecutive terms. Senior’s motion for new trial was denied in 2020. He did not file a timely appeal, but after a successful habeas corpus petition, he was granted an out-of-time appeal on the basis of ineffective assistance of counsel for failure to file a timely notice of appeal.The Supreme Court of Georgia reviewed the case. Senior’s sole claim on appeal was that trial counsel was ineffective for not impeaching two key prosecution witnesses with their prior felony convictions. The Supreme Court assumed, without deciding, that counsel’s performance was deficient but found no prejudice to Senior, given the strength of other eyewitness testimony and evidence against him. The Court affirmed the judgment, holding that Senior failed to demonstrate a reasonable probability that the outcome would have been different but for counsel’s alleged error. View "SENIOR v. THE STATE" on Justia Law

The case involves Rodriquez Lamont Hamilton, who was charged with felony murder and related offenses following the fatal shooting of Jamarius Cowart and the non-fatal shooting of Allysia Bryant in November 2022. At the time, Bryant and Hamilton were cohabiting but were no longer in a romantic relationship, with Bryant dating Cowart. The relationship between Bryant and Hamilton had a history of violence and conflict. On the night in question, Bryant and Cowart were shot while stopped at a traffic light, with Bryant identifying Hamilton as the shooter. Physical evidence, including shell casings and surveillance footage, supported Bryant’s account. Hamilton left the scene and later turned himself in to authorities.A Glynn County grand jury indicted Hamilton on multiple counts. At trial in December 2023, the jury acquitted him of malice murder but found him guilty of felony murder, aggravated assault, and possession of a firearm during a felony. The Superior Court of Glynn County sentenced Hamilton to life without parole plus consecutive prison terms for the other offenses. Hamilton filed a motion for a new trial, which was denied after a hearing.The Supreme Court of Georgia reviewed Hamilton’s appeal. Hamilton argued that the trial court abused its discretion by denying mistrials after a courtroom outburst and an officer’s remark about Hamilton’s silence, and by admitting evidence of prior difficulties between him and the victims. The Supreme Court of Georgia held that the trial court did not abuse its discretion in denying mistrials and that any error in admitting evidence of prior difficulties was harmless. The Court also rejected Hamilton’s claim of cumulative error. The judgment of conviction was affirmed. View "HAMILTON v. THE STATE" on Justia Law